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|CFPB Warns Credit Card Companies About Potential UDAAP Violations When Marketing Promotional Interest Rates|
Keith J. Barnett, B. Knox Dobbins, Brian M. Murphy, Robert J. Pile, Lewis S. Wiener; Sutherland Asbill & Brennan LLP;
September 11, 2014, previously published on September 8, 2014The Consumer Financial Protection Bureau (CFPB) issued a bulletin on September 3, 2014 warning credit card companies that marketing materials for promotional annual percentage rate (APR) offers may be in violation of the unfair, deceptive, or abusive acts or practices (UDAAP) provisions of the...
|CRA3 - Final Draft Regulatory Technical Standards in relation to Disclosure Requirements for Structured Finance Instruments|
Cadwalader Wickersham Taft LLP;
September 11, 2014, previously published on September 8, 2014On 24 June 2014, ESMA published its Final Report on the draft regulatory technical standards under CRA3 (as defined below) (the “Final Report”). With respect to structured finance instruments, the Final Report sets out draft standards for the information to be disclosed, the frequency...
|SAFE's New Circular 37 Enhances and Facilitates Round-Trip Investment Registration in PRC|
Patrick H. Hu, H. John Kao, Ian M. Liao, Jessie Chenghui Tang, Liming Yuan; Jones Day;
September 10, 2014, previously published on September 2014On July 14, 2014, China's State Administration of Foreign Exchange ("SAFE") issued the Notice on Relevant Issues concerning Foreign Exchange Administration for Domestic Residents Engaging in Overseas Financing and Investing through Round-Trip Investment via Special Purpose Companies...
|Know The Law: Know Your Rights When Dealing With Debt Collectors|
Andrew R. Hamilton; McLane, Graf, Raulerson & Middleton Professional Association;
September 10, 2014, previously published on September 2014Q: I received a voicemail yesterday from someone who said he was calling from a debt collection agency. I don’t believe that I am behind on any debt, what should I do?
|CFPB Issues Bulletin Regarding Marketing of Promotional Credit Card Offers|
Peter L. Cockrell, Brett M. Kitt, Gil Rudolph, J. Scott Sheehan; Greenberg Traurig, LLP;
September 10, 2014, previously published on September 8, 2014On September 3rd, the CFPB issued Bulletin 2014-02 warning credit card companies against deceptively marketing interest-rate promotions to consumers. The CFPB is concerned that consumers do not adequately understand certain types of credit card offers, such as balance transfers, deferred-interest...
|The CFPB Alerts Credit Card Issuers That Marketing of Credit Card Promotional APR Offers May Violate Federal Law|
Yesenia Garcia Perez; Foley & Lardner LLP;
September 9, 2014, previously published on September 4, 2014The Consumer Financial Protection Bureau (“CFPB”) recently issued a bulletin alerting credit card companies that they may be at risk of breaking the law as a result of the way they market promotional rates. Specifically, credit card issuers may be at risk of engaging in deceptive and/or...
|Is Your Baby Your Buyer’s Collateral?|
Michael J. Mozes; Foley & Lardner LLP;
September 9, 2014, previously published on September 4, 2014Even before dealing with the intricacies of nondisclosure agreements, employment offer letters, stock restriction agreements, and incentive plans, it is not unusual for founders to have already dreamt of an IPO or sale event. In fact, it is crucial for founders to consider when and how to make that...
|US Banking Regulators Adopt Final Rule to Impose Liquidity Coverage Ratio on Large US Banking Institutions|
Scott A. Anenberg, J. Paul Forrester, Carol A. Hitselberger; Mayer Brown LLP;
September 9, 2014, previously published on September 5, 2014The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC—and, together with the FRB and FDIC, Agencies), have each adopted a final rule (the Final Rule) to impose a quantitative...
|The Crucial Distinction Between Carrots and Sticks: Incentives and Penalties in the Interpretation of the Interest Act|
Timothy Froese; McCarthy Tétrault LLP;
September 9, 2014, previously published on September 3, 2014Do incentives for prompt payment in a mortgage, which would be lost on default, run afoul of the prohibition against penalties for non-performance contained in s.8 of the Interest Act? The Alberta Court of Appeal recently split over this question, with the majority saying no. This case could affect...
|Summary of Prudential Regulators’ Re-Proposed Margin Rules|
Steven Lofchie, Nihal S. Patel, Jeffrey L. Robins; Cadwalader, Wickersham & Taft LLP;
September 8, 2014, previously published on September 4, 2014On September 3, the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance Agency (collectively, the “Prudential...